PROTOCOL TO THE AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLE's REPUBLIC OF CHINA AND THE GOVERNMENT OF CANADA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE REVENTION OF FISCAL EVASION WITH RESPECT TO
颁布时间:1986-05-12
At the moment of signing the Agreement this day concluded between the
Government of the People's Republic of China and the Government of Canada
for the avoidance of double taxation and the prevention of fiscal evasion
with respect to taxes on income, the undersigned have agreed upon the
following additional provisions which shall be an integral part of the
Agreement.
1. With respect to paragraph 1 (e) of Article 3, the term "person"
also includes, in the case of Canada, an estate, a trust and a
partnership.
2. With respect to paragraph 1 (f) of Article 3, it is understood that
in French the term "société" also means a "corporation" as the word is
used in the Canadian law.
3. With respect to paragraph 1 of Article 6, the provisions shall also
apply to profits from the alienation of property referred to therein.
4. The provisions of the Agreement shall not be construed to restrict
in any manner any tax benefit which is or may hereafter be accorded in a
Contracting State by the laws of that Contracting State or by any
agreement between the governments of the Contracting States.
IN WITNESS WHEREOF the undersigned, duly authorized to that effect,
have signed this Protocol.
DONE in duplicate at Beijing, this twelfth day of May, 1986, in the
Chinese, English and French languages, each version being equally
authentic.
For the Government For the Government of Canada
of the People's Republic of China